Guidance For Implementing The Financial Integrity Act Guidelines Established By The Department Of Finance And Administration For Reports Due December 31, 2014.(revised 6/4/14)

Over the past several months the Department of Finance and Administration and Comptroller´s Office staff have been reviewing changes in the accounting profession regarding internal control and risk assessment. The Committee of Sponsoring Organizations of the Treadway Commission (COSO) has updated its original 1992 guidance on internal control with the publication of a revision in May of 2013. And the United States Government Accountability Office has responded with a 2013 Exposure Draft of Standards of Internal Control in the Federal Government, known as the "Green Book."

State agencies should continue to use the above worksheets and report format for the December 31, 2014 reports, making changes where necessary and appropriate. Additional guidance will be provided during 2015 for the December 2015 report.

Meanwhile, agency staff should familiarize themselves with the changes made by COSO in May of 2013. Of particular help is the revised draft of the Green Book published by the U.S. Government Accountability Office, as this document updates internal control from the perspective of government management. In preparation for the December 31, 2014 report, we suggest fiscal and internal audit staff review the documents listed below if they have not done so already.

A number of documents are available for free at the COSO site, including the executive summary link below. Also available for download on the COSO site is a PowerPoint presentation of the recent COSO changes.

As your department prepares for the annual issuance of its report addressing the agency-wide risk management and internal control requirements of TCA 9-18-102, please be reminded that your risk assessment should include PPACA related employment status compliance.

It is recommended that at a minimum, your control activities review (specifically Section VI, Part 2) include the identification of mitigating controls addressing the following risks:

Part-time employees work greater than an average of 30 hours per week over a 12 month period.

Vendor assigned temporaries work for periods exceeding 90 days per assignment.

Independent contractors work can be construed to be the same as a state employee and they work greater than an average of 30 hours per week over a 12 month period.